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Submission and Letters

The CLD regularly submits recommendations and letters to International Organizations and Governments. Find in this section a summary of these activities.

OGP Submission on Canada’s Fourth Open Government Partnership Action Plan, March 2018

The government of Canada is currently preparing its fourth Action Plan for the Open Government Partnership (OGP) and the Centre for Law and Democracy (CLD) has contributed a Submission to Ideas Discussion for Canada’s Action Plan on Open Government 2018–20. CLD has provided comments on all of Canada’s previous OGP action plans.


Letter to the Prime Minister on Canada’s Participation in the OGP, September 2017

In September 2017, the Centre for Law and Democracy and similarly concerned organizations issued a letter to the Prime Minister of Canada, Justin Trudeau, urging Canada to accept a leadership role in the Open Government Partnership, an important forum for advancing transparency and accountability in government.


CLD was part of a joint letter calling for the UNESCO to release a draft version of its access to information policy as soon as possible in order to receive civil society input.

Canada’s legal framework for charities is both outdated and unduly restrictive, a fact which became apparent when the regulator, the Canada Revenue Agency (CRA), launched a spate of charity audits a few years ago. The current Canadian government has signalled an intention to revise the rules in this area and, as part of that, the CRA is holding a consultation on the rules. CLD has provided a detailed Submission to that process, calling for extensive reforms.

Submission on the Right to Information and Intergovernmental Organisations, October 2016

The Centre for Law and Democracy prepared a Submission on the applicability of the right to information to intergovernmental organisations (IGOs) in response to a call for input from the UN Special Rapporteur on the Right to Freedom of Opinion and Expression. The Submission argues that IGOs are bound to respect human rights, including RTI. Currently, relatively few IGOs outside of the international financial institutions have adopted policies on RTI, but they are coming under increasing pressure to do so.


The Centre for Law and Democracy has prepared a set of Comments on the Council of Europe’s draft Guidelines on Civil Participation in Political Decision-Making. The Guidelines aim to set minimum standards for Council of Europe Member States in terms of ensuring participation in relation to processes of public decision-making. CLD very much welcomes this initiative – which can help improve consultation processes – but also has a number of suggestions for tightening up and improving the draft Guidelines.

These Recommendations were drafted by the Centre for Law and Democracy in response to a Call for Comment on the Canadian Government’s proposals to revitalise access to information put out by the Treasury Board of Canada Secretariat. To align with the purpose of the consultation, which focuses on the first phase – i.e. short term measures in advance of a full review – our Recommendations focus on those reforms which we believe are of great urgency to improve the functionality of the Access to Information Act. At the same time, we preface our specific Recommendations with some comments about manner in which the reforms are proposed to take place.


Submission to Ideas Discussion for Canada’s Action Plan on Open Government 2016-18, May 2016

This is the Centre for Law and Democracy’s (CLD) submission to the Government of Canada’s call for ideas to help shape Canada’s Action Plan on Open Government: 2016–18. We have participated in other Government of Canada Open Government Partnership (OGP) consultations and have been critical of Canada’s first two Action Plans for failing to address areas where reform is badly needed and for not paying sufficient attention to stakeholder inputs. However, we are hopeful that this Action Plan will incorporate strong and ambitious commitments, and we have made the following suggestions as priority areas for action in Canada.